2021 (2) TMI 73

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....ppeals by assessee are directed against the different orders of Ld. CIT(Appeals)-15, Delhi dated 09.10.2018 for above assessment years, challenging the levy of penalty u/s 271(1)(c) of the IT Act. 2. I have heard Ld. Representatives of both the parties and perused the material on record. 3. Briefly the facts are that the AO came into possessing the information that during the assessment year....

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.... since the notices are invalid and defective, therefore, penalty is not leviable against the assessee. Ld. Counsel for assessee relied upon the judgment of the Hon'ble Delhi High Court in the case of Pr. CIT vs. M/s Sahara India Life Insurance Company Limited, 2019 (8) TMI 409. 5. On the other hand, Ld. DR submitted that AO's failure to strike of column in show-cause is no ground for deleting t....

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....271(1)(c) of the Act, the penalty proceedings had been initiated i.e. whether for concealment of particulars of income or furnishing inaccurate particulars of income. The show-cause notices are, therefore, bad in law and illegal and, as such, the entire penalty proceedings are vitiated and no penalty is leviable against the assessee in any of the years. On this scope itself, similar views is taken....